It seems clear that a general government grant to a corporation was a grant to it with which the corporation had no prior knowledge. The purpose of the grant was to fund the corporation’s work. To understand whether a payment to a corporation for a specific purpose was to be construed as an asset or liability, one must first understand that an asset in this context means an asset given from the government by the state or other government entity with which the corporation might become involved in state-licensed activities. By contrast, the liability for a specific purpose is a liability for a specific purpose. The government is the source of its own money and cannot provide a single individual with an unlimited amount of money to spend. Therefore, such an idea would be utterly antithetical to the spirit of the Constitution.
Furthermore and more fundamentally, a grant of the power to tax to a corporation is not even an asset that a corporation could have in connection with its existing activities. Insofar as the power to tax is vested in a state or local government, the company is in no position to tax the income it earns in the state or other taxing jurisdiction and can exercise none of its rights through contracts to make dividends to the state or other taxing jurisdiction with which it has any connection. Thus, the grant of the power to tax, in and by itself, no more gives the corporation authority over the income in its possession than do a bank or even a credit union.
However, it is apparent that an asset or liability to be construed as an asset or liability in a particular jurisdiction would require the legislature and public official to have a factual connection between the entity and the taxpayer. One would not understand from the record before us, therefore, that there was no connection between the State of New Jersey and the individuals who filed the tax returns in the name of the Corporation for Economic Development. The court also clearly failed to identify in its opinion the specific factual basis on which it would have held the corporation liable if taxes were to have been owed. A grant of the power to tax to a corporation was merely merely a grant of the power to tax. The court’s opinion and subsequent actions are not inconsistent with the principles and reasoning contained in the cases cited above, which clearly established that the legislature and public officer had neither reason nor authority to hold the Corporation liable for the taxes on its income.
The court’s holding as to the property interest of the Corporation and also as to its liability for the tax, therefore, were without substance. As to the corporation’s liability, the court
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